The First and Fourteenth Amendments of the United States Constitution apply to "'severely circumscribe'" the role of civil courts in litigation involving religious institutions. (Serbian Orthodox Diocese v. Milivojevich (1976) 426 U.S. 696 (Milivojevich).) "Where resolution of the disputes cannot be made without extensive inquiry by civil courts into religious law and polity, the First and Fourteenth Amendments mandate that civil courts shall not disturb the decisions of the highest ecclesiastical tribunal within a church of hierarchical polity, but must accept such decisions as binding on them, in their application to the religious issues of doctrine or polity before them. " (Ibid.) "The prohibition against civil court participation in sectarian disputes extends to issues involving membership, clergy credentials and discipline, as well as religious entity governance and administration. (Jones v. Wolf (1979) 443 U.S. 595, 602, 603-604; Concord Christian Center v. Open Bible Standard Churches (2005) 132 Cal.App.4th 1396 at p. 1411.)" ( New v. Kroeger (2008) 167 Cal.App.4th 800, 815 84 Cal. Rptr. 3d 464.) "By definition, a hierarchical church is one in which individual churches are 'organized as a body with other churches having similar faith and doctrine, and with a common ruling convocation or ecclesiastical head' vested with ultimate ecclesiastical authority over the individual congregations and members of the entire organized church. It has long been established that in such a hierarchical church, an individual local congregation that affiliates with the national church body becomes 'a member of a much larger and more important religious organization, ... under its government and control, and ... bound by its orders and judgments.' In contrast, a congregational church is defined as one 'strictly independent of other ecclesiastical associations, and one that so far as church government is concerned, owes no fealty or obligation to any higher authority.' " (Concord Christian, supra, 132 Cal.App.4th at p. 1409.) As originally stated by the United States Supreme Court, within a hierarchical religious entity "whenever the questions of discipline, or of faith, or ecclesiastical rule, custom, or law have been decided by the highest of these church judicatories to which the matter has been carried, the legal tribunals must accept such decisions as final, and as binding on them, in their application to the case before them." (Watson v. Jones (1871) 80 U.S. 679, 727 20 L. Ed. 666.) There are limited exceptions to the general rule of judicial deference to ecclesiastical decisions. When a property dispute between two religious groups is susceptible to the application of neutral principles of law, it is proper for the civil courts to apply those principles to the dispute, rather than deferring to the adjudicatory bodies of the relevant ecclesiastical organizations. (Jones v. Wolf, supra, 443 U.S. at p. 604 application of religiously neutral principles permits the court to examine religious documents for language purporting to create trusts in favor of the general church.) As the California Supreme Court recently clarified, "State courts must not decide questions of religious doctrine; those are for the church to resolve. Accordingly, if resolution of a property dispute involves a point of doctrine, the court must defer to the position of the highest ecclesiastical authority that has decided the point. But to the extent the court can resolve a property dispute without reference to church doctrine, it should apply neutral principles of law. The court should consider sources such as the deeds to the property in dispute, the local church's articles of incorporation, the general church's constitution, canons, and rules, and relevant statutes, including statutes specifically concerning religious property, such as Corporations Code section 9142." (Episcopal Church Cases (2009) 45 Cal.4th 467, 485.)